Aug. 05, 2020 - The IRS recently released long-awaited final regulations (Final Regulations) on the limitation on the deductibility of interest expenses under section 163(j), along with new proposed regulations (New Proposed Regulations) that address a variety of highly technical issues that are not covered by...
Onerous US Reporting Requirements for US Members of Non-US Family-Controlled Entities: It’s All in the Family
Family wealth and business planning often gives rise to structures that come with burdensome reporting obligations for minority US shareholders. In this Canadian Tax Journal article, Davies partners Peter Glicklich and Gregg Benson point out some of the cases where the burden is much larger than it should be, requiring information that would not ordinarily be shared with the younger generation.
July 22, 2020 - The U.S. Treasury Department and the IRS have released final regulations (2020 Final Regulations) allowing certain domestic shareholders of a “controlled foreign corporation” (CFC) to elect under a high-tax exception to opt out of the tax imposed on the CFC’s “global intangible low-taxed...